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For extra data on filing a bit 45 election, please contact our skilled Canadian tax lawyers. However, in certain situations, regardless of the property worth, the Deemed Disposition rule won’t be applicable.
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Further, the Tribunal has not seen evidence that Respondent delayed or refused to problem visas with the intent to cause money move delays or different difficulties for Sehil or as part of a transparent policy to expropriate Claimants’ investment. It is not Turkmenistan or its Ministry of Foreign Affairs that made a promise to Sehil to concern visas or to assist in acquiring visas and to do so on time. The Tribunal additionally considers that delays in issuing visas, even if sustained, don’t quantity to oblique expropriation.